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Have a strategy. Adjust the scope of your requests to the questions at issue. Send clear requests. Always consider how your client would be prepared to respond to similar requests. Make your objections clear and specific.
When responding to Requests for Admissions, remember to answer as follows: Admit: If any portion of the Request for Admission is true then you must admit to that portion of the request. You are also allowed to have a hybrid response admit the part of the request that is true while denying another part.
Your name and address. The Court's name. The title of the case. Case number. Fill your name in as the Requesting Party. On the following pages, choose which questions you wish to ask by checking boxes next to the questions you wish to ask.
The plaintiff must respond to your requests for discovery. The plaintiff must respond by the deadline. There are different ways to make sure you get each kind of discovery if the plaintiff does not give it to you by the deadline.
Your answers to the interrogatories should usually be short, clear, and direct and should answer only the question that is being asked. This is not the time to set out your entire case or defense to the other side. Take the time to make sure your answers are correct and truthful.
Requests for Admissions involves one party asking the opposing to admit, deny, or prove the validity of certain facts or documents. This portion of the discovery saves time during the trial and allows the party to trust the facts or documents in question.
You must answer each interrogatory separately and fully in writing under oath, unless you object to it. You must explain why you object. You must sign your answers and objections.
Be concise when answering narrative questions. Provide accurate, complete information, but do not answer more than is necessary. If adding some particular details will help your case, then include them. But do not feel compelled to include details that may not help your case.
Organize documents. Organize according to the demand number. Don't duplicate documents. If you're providing three years of bank statements in response to one demand, and the same documents contain information responsive to another demand, state so. Comply with the due date. Communicate. Do a complete job.